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February 20, 2015
Christine Crofton, Ph.D.
CAHPS Program Director
Center for Quality Improvement and Patient Safety
Agency for Healthcare Research and Quality
540 Gaither Road
Rockville, MD 20850
RE: Notice of Proposed Changes for the Consumer Assessment of Healthcare Providers and
Systems (CAHPS) Clinician and Group Survey, Federal Register Vol. 80, No. 13, January 21,
2015
Dear Dr. Crofton:
On behalf of our nearly 5,000 member hospitals, health systems and other health care
organizations, and our 43,000 individual members, the American Hospital Association (AHA)
appreciates the opportunity to comment on the Agency for Healthcare Research and Quality’s
(AHRQ) proposed changes to the Clinician and Group Consumer Assessment of Healthcare
Providers and Systems (CG-CAHPS) patient experience survey. The proposed changes also
address the Patient-Centered Medical Home (PCMH) item set, which is used in combination
with CG-CAHPS to create the CAHPS PCMH Survey.
AHRQ proposes several changes to reduce patient and provider burden, yet retain important
information, promote consistency across CAHPS surveys and maintain the reliability of CAHPS
measures. Specifically, AHRQ would move several “core” CG-CAHPS and PCMH item set
questions to its list of “supplemental” questions. The resulting core CG-CAHPS survey would be
reduced from 34 to 31 questions, and the core PCMH set would be reduced from 18 to six
questions. AHRQ also proposes to change the reference time period for each survey question
from “in the last 12 months” to “in the last six months.” This change would make the core CGCAHPS consistent with the version of the survey being implemented by the Centers for
Medicare & Medicaid Services (CMS) in its Physician Quality Reporting System (PQRS)
program.
The AHA applauds AHRQ’s proposal to shorten the CG-CAHPS survey and the PCMH
item set, and agrees these changes would reduce patient and provider burden. However, we
urge the agency to take additional steps to reduce burden further by supporting the
Christine Crofton, Ph.D.
February 20, 2015
Page 2 of 3
development of lower-cost survey administration options. In addition, we ask the agency to
explain and provide more analysis to support its proposal to use a six-month instead of a
12-month timeframe for survey questions.
We provide more detail on each of these recommendations below.
REDUCING SURVEY BURDEN
The AHA supports AHRQ’s proposal to reduce the number of survey questions, and
believes this reduction is an important first step toward a more effective survey tool. The
AHA has long favored the use of patient experience surveys as tools to help providers improve
the engagement and satisfaction of patients and their families. However, the proliferation of
questions on such surveys has resulted not only in substantial costs to providers to collect the
data, but also a significant burden to patients. Indeed, many patients have expressed frustration to
our members about the length of surveys and the amount of time it takes to complete them. It is
critical that surveys include a parsimonious set of questions so that valuable patient time and
finite provider resources are used efficiently and effectively.
However, we urge AHRQ to reduce survey burden further by supporting the development
of lower-cost survey administration approaches – such as emailed or web-based surveys.
The use of more economical survey approaches is especially important because patients now
may receive multiple surveys from the CAHPS “family,” including surveys for hospitals, nursing
homes, dialysis facilities and home health agencies. While we appreciate the value of assessing
the patient experience across the care continuum, the use of multiple surveys means more time
spent by patients to answer surveys, and more resources expended by providers to administer
them. Moreover, for the purposes of CMS reporting programs using CAHPS tools, providers are
permitted to use only two survey administration modes – mailed surveys and telephone surveys.
Mailed surveys are relatively inexpensive to administer, but often suffer from low response rates
and a significant time lag. Telephonic surveys typically yield a higher response rate and provide
more timely results, but are much more expensive to administer.
We strongly encourage AHRQ to work with the CAHPS consortium to develop guidelines for
emailed and web-based surveys for the entire CAHPS family. Once this guidance is developed,
AHRQ also should encourage CMS to permit the use of emailed and web-based surveys in CMS
reporting programs. To date, AHRQ has provided very limited guidance on appropriate
procedures for using electronic survey methodologies. Yet, electronic survey administration
modes, such as email and web-based portals, make survey data collection and aggregation
timelier and less expensive, and may allow hospitals to increase sample size without greatly
increasing cost. In developing guidance for emailed and web-based surveys, AHRQ also should
engage with hospitals and other providers that have been using emailed and web-based surveys
to collect data on patient experience informally.
Christine Crofton, Ph.D.
February 20, 2015
Page 3 of 3
SURVEY TIMEFRAME
The AHA asks AHRQ to explain and make its analysis publicly available to support its
proposal to use a six-month timeframe instead of a 12-month timeframe for survey
questions. Our members enthusiastically support efforts to align and streamline federal quality
measurement efforts, and we appreciate that AHRQ wishes to foster alignment with CMS
reporting programs. However, we do not feel we have sufficient information at this time to lend
our support to this proposal. In the Federal Register notice, AHRQ notes that “a study that
randomized patients to a 12-month or 6-month survey version yielded similar CAHPS scores at
the practice site level.” However, AHRQ does not share the detailed methodology and results of
the study. These details are important because the use of a shorter survey timeframe would likely
impact the reliability of survey data for some practices. In particular, smaller practices may find
it difficult to obtain a statistically sound sample of responses.
If AHRQ is intent on making a six-month timeframe the standard for the survey, we also
encourage the agency to work with CMS to ensure its survey administration practices are aligned
with this approach. For the purposes of PQRS, CMS attributes patients to a physician group
based on whether that group provides the plurality of primary care services to the patient during
an entire calendar year. CMS then randomly selects a sample of each practice’s attributed
patients to whom survey vendors administer the survey. This approach appears to be inconsistent
with the use of a six-month survey timeframe.
Thank you for the opportunity to comment, and we look forward to continuing to work with you
to improve the CAHPS surveys. If you have questions, please contact me or Akin Demehin,
AHA senior associate director for policy, at (202) 626-2365 or [email protected].
Sincerely,
/s/
Linda E. Fishman
Senior Vice President
Public Policy Analysis and Development